HIPAA Notice of Privacy Practices
Effective Date: October 9, 2026
This notice describes how health information about you may be used and disclosed and how you can get access to this information. PLEASE REVIEW IT CAREFULLY.
Why We Collect Health Information
While we do collect health information from you, this is done solely to provide you with the best possible educational experience. By understanding your specific health profile, injury history, gaming habits, and physical condition, we can:
- Provide personalized educational content tailored to your specific needs
- Recommend appropriate exercises and load management strategies
- Track your progress and adjust educational recommendations accordingly
- Deliver relevant information that matches your current health status
- Ensure the educational content is most beneficial for your situation
This personalized approach helps us deliver more effective educational resources while maintaining the highest standards of privacy protection.
Our Commitment to Your Privacy
1HP Troubleshooter is committed to protecting health information about you. We create a record of the educational content and services you access through our platform. We need this record to provide you with personalized educational content and to comply with certain legal requirements.
IMPORTANT DISCLAIMER: 1HP Troubleshooter is an educational platform only. We do not provide medical treatment, diagnosis, or medical advice. Any use of the educational information provided for treatment purposes is done at your own risk and liability.
How We May Use and Disclose Health Information
We may use and disclose your health information for the following purposes:
For Educational Services
We may use your health information to provide you with personalized educational content, exercise recommendations, load management guidance, and recovery tracking information. If you opt in to 1HP Clinical Brain (our AI coach), we also use your record and the messages or speech you send so it can generate educational replies, homework, and notes saved to your record. How that works, where it is processed, and the safeguards around it are described in the section How Our AI Coach Uses Your Information below. We do not disclose your information to healthcare providers or other third parties for treatment purposes. All content provided is for educational purposes only.
For Payment
We may use and disclose your health information to bill and collect payment for services provided to you. This may include certain activities that your health insurance plan may undertake before approving or paying for services.
For Platform Operations
We may use and disclose your health information for our platform operations, including quality assessment of educational content, improvement activities, reviewing effectiveness of educational programs, and conducting training programs for our educational content development.
As Required by Law
We will disclose your health information when required to do so by federal, state, or local law.
How Our AI Coach (1HP Clinical Brain) Uses Your Information
1HP Clinical Brain is an AI coach built by 1HP clinicians. It runs a weekly coaching visit in the Coaching Tool on your dashboard and answers short questions between visits in the Clinical Brain chat. It is coaching support for the educational program. It does not diagnose, it is not a substitute for a clinician, and it is not for emergencies.
It Is Opt-In
The AI coach is only available on accounts we have enabled it for, and it does not read your record until you have reviewed how it works and given your explicit consent inside the app. Your consent covers two things: the coach reading your record to coach you, and our use of de-identified information from your record and your conversations with the coach to train and improve future versions of it (see "Improving the Coach" below). Your consent is recorded with the date, time, and the version of the consent language you agreed to. Every request the coach handles is checked on our servers against that consent; if consent is not on file, the request is refused and the refusal is logged. You can opt out at any time from Account Settings → Data & Privacy (see "Opting Out" below).
What It Reads
When you use the coach, it is given the parts of your Troubleshooter record relevant to coaching you:
- Your assessment answers, pain regions, and mobility, nerve mobility, and endurance test results
- Your QuickDASH and Fear-Avoidance Components Scale (FACS) questionnaire scores
- Your exercise prescriptions and the sessions you have logged
- Your load tracking entries and irritability history
- Your Pain Science Hub entries (lesson reflections, checklist results, journals, and other exercises)
- Notes 1HP clinicians have written in your chart
- Your previous chats and coaching sessions with the coach, and your homework
- The messages you type and, if you choose to use voice, transcripts of what you say
What It Creates
The coach produces educational replies, homework items, and session notes. Chats, session transcripts, homework, and the notes it writes are saved to your 1HP record and can be read by 1HP clinicians, who may review them the same way they review any other part of your chart. 1HP staff can also use the coach to generate a summary of your record or an initial evaluation note for clinician use. Clinician-only material in your chart, such as provider reasoning, is labeled so the coach does not repeat it to you, and a final check removes that vocabulary from replies if it appears.
Where It Is Processed and Our Agreement With Google
The AI coach runs on Google Cloud's Vertex AI platform inside 1HP's own Google Cloud project, the same project that stores your Troubleshooter record. 1HP has a Business Associate Agreement (BAA) with Google Cloud, and Vertex AI, the speech recognition service, and the database and storage services we use are covered by it. This means Google is contractually bound to HIPAA safeguards for the protected health information it processes on our behalf.
- The language models the coach uses (Google's Gemini models and Anthropic's Claude models) are served through Vertex AI. Under Google's Vertex AI terms, your prompts and the model's responses are not used to train Google's models or its partners' models, and partner models are hosted inside Google Cloud, so your information is not sent to the model developer.
- Your information is encrypted in transit and at rest within Google Cloud.
- Google and the model providers do not train on your information. Any training or improvement of the coach is done by 1HP, only with your consent, and only on de-identified information, as described next.
Improving the Coach
With your consent, we use what members write and say to the coach, and the parts of their record the coach uses, to train and improve future versions of it, alongside 1HP's own clinical guidance and past consultation transcripts. Before any of this information is used for that purpose, it is de-identified: names, email addresses, phone numbers, Social Security numbers, account handles, postal codes, record numbers, and other direct identifiers are removed, and 1HP clinicians spot-check the result. De-identified material carries no link back to your account. It cannot be traced back to you and is not removed if you later opt out.
Voice is optional. If you use the Talk button, your recording is sent to a speech recognition service only to produce a transcript, and if you choose the "Elliot" voice, the text of the coach's reply is sent to a speech synthesis service only to produce the audio. These voice features are provided by ElevenLabs, with Google Cloud Speech-to-Text as a fallback for recognition. Recordings and audio are not stored by us after the transcript or audio is returned. If you would rather keep voice processing on your own device, choose the "Browser" voice and type your replies instead of using Talk.
Safeguards
- Access controls. The coach must be enabled on your account by 1HP staff and consented to by you. Both are verified on our servers on every request; nothing in the app can bypass that check.
- Audit logging. Every time the coach reads your record, every consent change, every change to the coach's enablement on your account, and every refused request is written to a tamper-resistant audit log that only our servers can write and only administrators can read.
- Separation of clinician-only information. Provider briefs, escalation flags, and call history are stored where only administrators can read them. Your chat transcripts are written only by our servers.
- Data minimization. The coach is given the parts of your record relevant to the conversation, and the transcripts used to build its clinical knowledge are de-identified first.
- Session expiry. Signed-in sessions expire after a period of inactivity.
- Retention. Coaching chats, sessions, and notes are part of your record and are kept under the same retention rules as the rest of your chart, until you opt out.
Opting Out
Once you have consented, Account Settings → Data & Privacy offers an "Opt Out of AI" option. Opting out takes effect immediately and:
- turns off the Coaching Tool and the Clinical Brain chat for your account and withdraws your consent, so the coach no longer reads your record;
- deletes your chats, coaching sessions, homework, and coaching progress;
- moves the notes the coach wrote to your chart, its provider brief, and any escalation flags out of your live record and into our retained clinical records, which only 1HP clinical staff can access and which we keep as required by medical record-retention law;
- excludes your information from any future training or improvement of the coach.
Your exercise program, load tracking, and the rest of your account are not affected. Access logs are retained as required by law. Information that was de-identified before you opted out cannot be traced back to you and is not removed. To use the coach again after opting out, contact admin@1-hp.org.
Your Choices
You may use the Troubleshooter without the AI coach; nothing about your educational program depends on it. You may decline consent, opt out later, turn voice features off, and request a copy of your record, including your coaching chats and notes, under your rights described below.
Your Rights Regarding Health Information
Right to Inspect and Copy
You have the right to inspect and copy your health information that may be used to provide you with educational content.
Right to Amend
If you feel that health information we have is incorrect or incomplete, you may ask us to amend the information.
Right to an Accounting of Disclosures
You have the right to request an accounting of disclosures of your health information made by us.
Right to Request Restrictions
You have the right to request a restriction or limitation on the health information we use or disclose for educational services, payment, or platform operations.
Right to Request Confidential Communications
You have the right to request that we communicate with you about health matters in a certain way or at a certain location.
Right to a Paper Copy of This Notice
You have the right to a paper copy of this notice at any time.
Breach Notification
We are required to notify you if there is a breach of your unsecured protected health information.
Complaints
If you believe your privacy rights have been violated, you may file a complaint with us or with the Secretary of the Department of Health and Human Services. You will not be penalized for filing a complaint.
Contact Information
For more information about our privacy practices or to exercise your rights, please contact:
Privacy Officer
Email: admin@1-hp.org
Changes to This Notice
We reserve the right to change this notice and make the revised notice effective for health information we already have as well as any information we receive in the future.